What is the role of the financial system
in an economy?
One of the important roles of a financial system
is to create a conducive financial environment
which encourages efficient financial intermediation
and bridge the gap between depositors, lenders
and the borrowers. In its simplest terms, banks
mobilize money from savers and make loans, at
risk to the borrowers, for a profit. In this
way banks help mobilize the savings of a nation
for productive investments and use in the economy.
What is the role of the Royal Monetary
Authority of Bhutan (RMA) with regard to the
banking/financial system?
From the Regulatory and Supervisory perspective,
the Financial Institutions Act of Bhutan 1992
has empowered the RMA to promulgate sound banking
and financial policies within the economy. These
activities would include issuing of licenses
for financial services, prescribe and implement
appropriate prudential regulations and guidelines
within the framework of which the financial
institutions will have to operate, and see to
their compliance through continuous off-site
surveillance system and frequent on-site examinations.
As the supervisory authority, it is the responsibility
of the RMA to monitor how the financial institutions
manage their risks and to promote a sound and
efficient financial system within the country.
To summarize the above, the health and financial
performance of both banks and non-bank financial
institutions are assessed from time -to-time
by the RMA. Such assessments are being evaluated
based on capital adequacy, asset quality, management
competency and professionalism, profitability,
liquidity management, and internal controls
and systems. Because of their important role
in the economy, banks and NBFIs have to be regulated
to ensure they are prudently managed.
Why do banks and NBFIs still fail despite
regulation and supervision?
Banks and NBFIs make profit by taking calculated
financial risks. Among the many types of risks
that the financial institutions have to manage
are credit risk and liquidity risk. Credit risk
is a common cause of problems because the liabilities
of financial institutions are largely certain
in value but the assets are uncertain in value.
In other words, the financial institutions must
still repay the full amount of deposit liabilities/liabilities
even though the loans made by the financial
institutions are those same funds, which are
not repaid by the borrowers. With the margin
between borrowed and lent funds often being
just a few percentage points, it should be clear
that just a few bad loans that are not repaid
will wipe out the profits made on many loans.
For this reason, banks and NBFIs are required
to hold a buffer of capital so that depositor
funds are kept intact even if there are unexpected
losses. Unfortunately, it can happen that unforeseen
events result in a spate of bad loans which
can wipe out the capital of a bank.
The most common underlying cause for bank failure
is actually poor management. For instance, if
the credit granting and debt collection processes
are not extremely well managed, a bank is almost
certain to feel the effects thereof in its profitability
and eventually its capital adequacy in the very
near future or sometime at a later stage.Despite
regulation and supervision, financial institutions
do fail in a financial system.
This is due to the fact that supervision is
not a full-proof shield against bank/NBFI failures.
It must be construed that regulation and supervision
are tools geared towards prevention of such
failures, which may cost the government and
public heavily if it happens. But, certainly
not an end in itself to completely stop bank
failures.
How is a liquidity problem distinct from insolvency?
To exacerbate the problem with credit risk,
banks are also naturally prone to liquidity
risk. This is so, because the liabilities of
banks are often relatively short-term in nature
and the assets relatively invested in longer
term. In other words, banks often obtain funding
from depositors that can be withdrawn within
days or months, but they lend to businesses
and households who can only repay the loans
over many years. Fortunately, deposits are "rolled
over" all the time, and banks can usually
manage liquidity quite well. They are also required
to hold a certain amount of their assets in
liquid assets that can be quickly turned into
cash. Un-seemingly, it sometimes happens that
a negative sentiment about a bank can cause
many depositors to withdraw at once, which can
cause a liquidity problem. This is not as serious
as a solvency problem, where losses have wiped
out capital and liabilities exceed assets. In
the case of a liquidity squeeze at a clearly
solvent bank, there are often many ways to avert
the problem. These can include private sector
involvement, for example the selling of good
loan assets to other banks, or in particular
circumstances special liquidity assistance by
the lender of last resort or by the government.
When and how do the regulatory authorities
intervene to assist banks/NBFIs in distress?
The bank supervisor relies on several sources
of information about impending problems at banks
or NBFIs. At the first sign of trouble well-established
procedures are put in place to resolve the problems.
These may include re-structuring of activities,
changes in management, and re-capitalisation
by shareholders. Unfortunately, in certain cases
the problems that the financial institutions
face could be so severe that they simply cannot
be resolved in terms of normal business principles.
For instance, the bank made a strategic error
in pursuing a particular market niche, and technological
developments have resulted in it being marginalised.
In such cases, it is in the best interest of
depositors for such a bank to be liquidated
and removed from the banking system in an orderly
fashion.
When and how do the authorities intervene to
assist banks in distress?
The bank supervisor relies on several sources
of information about impending problems at banks.
At the first sign of trouble well-established
procedures are put in place to resolve the problems.
These may include re-structuring of activities,
changes in management, and re-capitalisation
by shareholders. Unfortunately, in some cases
the problems that the bank faces are so severe
that they simply cannot be resolved in terms
of normal business principles. For instance,
the bank made a strategic error in pursuing
a particular market niche, and technological
developments have resulted in it being marginalised.
In such cases it is in the best interest of
depositors for such a bank to be liquidated
and removed from the banking system in an orderly
fashion.
What is Lender of
Last Resort (LOLR) assistance and when is it
applicable?
In some cases the underlying causes of a bank's
problems can be sustainably resolved, and the
only remaining issue is a short-term liquidity
problem. In such cases the RMA may provide special
short-term liquidity assistance, also known
as lender of last resort assistance (LOLR).
There are particular prescribed circumstances
and conditions under which special liquidity
assistance can be provided. Such assistance
could be expensive to the bank being assisted,
because the central bank needs to create a disincentive
for its use.
What can be done
to prevent harm to depositors when banks fail?
The most difficult part for the authorities
is to structure and time their intervention
in such a way that, although shareholders may
lose their risk capital, depositors are fully
reimbursed. A key mechanism to aid with this
is the curator mechanism. The appointment of
a curator to a bank is a way to ensure that
the actions to protect depositors take place
in an orderly, controlled and equitable way.
The curator has legal powers to implement actions
in the interest of all depositors, which the
management of the bank does not have. For instance,
if there is a run on a bank, depositors that
are unable to drop everything and rush to the
bank may be disadvantaged, yet the management,
unlike the curator, cannot refuse to pay out
the early withdrawals.
How does curator-ship
work?
The first thing that happens is that the curator
takes over the management of the bank, freezes
all deposits, and suspends certain other activities.
The curator's team (comprising some outside
experts but mainly existing bank staff who are
considered to be key to the achievement of the
task of the curator) then analyses the liquidity
position of the bank and determines a threshold
up to which the bank can immediately pay every
depositor. The threshold and procedures to conduct
withdrawals are usually announced within a few
days. In most cases the large majority of deposits
are below the threshold, and can be fully paid
out within days. Depositors with larger balances
may be allowed to access only up to the threshold,
and may have to wait until the task of the curator
is completed for the rest. The curator, then
proceeds to analyze the business of the bank
and endeavors to either re-position it as a
viable concern, or obtain the best possible
deal in the interest of the depositors. While
it is conceivable that the bank can be saved,
or a buyer for the whole bank can be found,
this is unlikely, as in such a case it would
have been sold in the market place long before
curator-ship. Often the bank is unbundled, and
different parts of its business are sold to
different banks. Sometimes a "scheme of
arrangement" is conceived whereby depositors
and creditors agree to a settlement of some
kind. While these negotiations with potential
buyers are proceeding, the curator's team tries
to terminate as much as possible of the leases
and other cost commitments of the bank, and
generally winds down operations. If the bank
or any part of it cannot be sold or re-positioned
as a viable concern, the curator makes a recommendation
to the Registrar that the remaining parts of
the bank must be liquidated. A liquidator is
appointed, who proceeds to liquidate all assets,
unfortunately often at prices below their real
worth, and finally pays all remaining depositors
a pro rata amount.Unless the bank was either
in reality deeply insolvent, or something caused
its assets to lose value rapidly, the depositors
will ultimately be fully, or almost fully, repaid.
Other creditors will then be paid, and the bank
deregistered and terminated. Unfortunately,
depending on circumstances, this entire process
can take more than a year.
Why can clients of
banks not be warned in advance of impending
problems?
Sometimes the event that causes a run is so
sudden and unexpected that the authorities do
not have a clear understanding of the problem.
In some ways the curator-ship is an opportunity
to stabilize the situation so that the true
circumstances can be assessed and plans developed
to resolve the problem. But normally the authorities
have advance warning about problems at a bank.
The first objective is always to find a sustainable
resolution to the problem long before it threatens
depositor funds. The process of analyzing the
issues and developing plans to resolve the problems
in a sustainable manner carries on while the
bank continues with normal business. Often the
situation deteriorates further before the changes
made start taking effect. If the authorities
where to communicate with depositors about their
concerns with the bank it would not only detract
from their efforts to find a solution, but also
possibly precipitate the very thing that they
are working to avoid, namely a run on the bank.
It is therefore standard practice for regulators
worldwide to refrain from ever commenting on
the affairs of a bank. A regulator would normally
only confirm the licensed status of a bank,
which implies that it is still in compliance
with the regulatory prudential requirements.
What is deposit insurance?
A deposit insurance scheme involves the collection
of a small premium from depositors to protect
them from losses arising from the closure of
a bank. Deposit insurance can distort the risk-reward
decision-making process and therefore the effectiveness
of market discipline to ensure that banks are
well managed. As a result, it is almost always
aimed at protecting only small depositors up
to a certain amount. Provided it is well funded
and can pay small depositors quickly and efficiently,
a deposit insurance scheme can be of great value
in improving confidence and in reducing hardship
in case of bank failure. It should be remembered,
however, that large institutional depositors
are still expected to assess the risks of depositing
with banks, and the better they do their jobs,
the sooner they will be to withdraw their deposits
from banks at the first sign of trouble. A deposit
insurance scheme will therefore not necessarily
avert a run on a bank or prevent curator-ship.
It does have the advantage that it makes the
process of paying back small depositors so much
more orderly, equitable and transparent.
Will problems in one bank affect other banks?
It is quite often assumed that problems in one
large bank will automatically spillover to other
banks and endanger the system. This is a fallacy,
as there is no empirical evidence to support
this. In all banking crises in recent times,
the problems became systemic only where other
banks were all exposed to more or less the same
extraneous risk, for example a rapid asset price
decline, a massive capital outflow, or a sharp
commodity price change.
The risk profile of spillover effects within
a financial system could be high under situation,
where there are inter-linkages of cross-shareholdings
or relative over dependence amongst financial
institutions.